Memorandum, December 9, 2013 Page 1 of 5



### MEMORANDUM

TO: Andrea Siefers, US EPA/SPPD/RCG

FROM: Philip Crawford and Colin Hayes, ERG

DATE: December 9, 2013

SUBJECT: Summary of May 22, 2013 Meeting Between US EPA and The Vinyl Institute

1.0 Introduction

On May 22, 2013, a teleconference meeting was held at the request of the Vinyl Institute (VI) and their member companies (henceforth, “the i ndustry) to present information to the EPA and its contractor, ERG, in advance of EPA’s planne d proposal to respond to petitions for reconsideration that EPA granted on the National Em ission Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl Chloride and Copo lymers (PVC) Production, which were promulgated on April 17, 2012.

2.0 Date and Location

May 22, 2013

Teleconference U.S. Environmental Protection Agency 109 TW Alexander Drive Durham, NC 27709

3.0 Attendees

Name Affiliation Richard Krock Vinyl Institute Mary Bachynsky Formosa Plastics Jean-Cyril Walker Keller & Heckman Greg Clark Keller & Heckman
Ted Nickerson Axiall
Dave Goldsmith AxiallMemorandum, December 9, 2013 Page 2 of 5

Kevin Bloomer Westlake Chemical
Allen Bodron Westlake Chemical Otis Sistrunk PolyOne Mark Pettigrew PolyOne Andy Sheppard URS Barry Christensen OxyChem John Westendorf OxyChem Laura Whiting OxyChem
David Wise Shintech
Tom Anderson Shintech
James Bell Shintech
Bob Elam Dow
Mark Kataoka EPA Penny Lassiter EPA
Andrea Siefers EPA
Steff Joshnson EPA Colin Hayes ERG Ashley Wong ERG Philip Crawford ERGMemorandum, December 9, 2013 Page 3 of 5

4.0 Summary of Meeting The VI provided an agenda ahead of the meeting, which is att ached. The following are summaries of the information presente d by the industry.

1. Area Sources - Generally available control technology (GACT) limi ts

• The industry representatives noted that hydrogen chloride (HCl) measurement data for OxyVinyls Deer Park facility were not included in EPA’s process vent MACT floor calculations. The industry representatives elaborated that EPA had approved the submission of HCl data collected by Deer Park prior to the August 2009 Section 114, and that the Deer Park facility had included t he HCl measurement data in their Section 114 response.

• The industry representatives pointed out that several o f the finalized GACT limits are more stringent than the Part 61 NESHAP for PVC fac ilities. They described the history of allowing reduced monitoring, recordkeeping, and reporting requirements for area sources, and they requested that th e EPA consider proposing such reduced requirements for PVC area sources.
2. Limits for Vent Gas Absorbers

• The industry representatives discussed challenges regar ding the application of the process vent emission standards to vent gas absorption ( VGA) units. They reiterated their comments from their June 18 th , 2012 petition for reconsideration, noting that VGAs are fundamentally different and that oxygen correction is not applicable to non-combustion control devices. They request ed the EPA to consider the possibility of alternative emission limi ts (e.g., mass or percent reduction based standards) for VGAs.
3. Bypasses from Closed Vent Systems

• The industry representatives presented the points set f orth in their June 18, 2012 petition regarding bypasses from closed vent systems.
4. Pressure Relief Device Requirements

• The industry presented issues raised in their petition r egarding monitoring of pressure relief devices (PRDs).
5. Leak Detection and Repair for Pressure Vessels

• The industry representatives requested that EPA consider proposing to include a definition for “potential leak interface,” and suggested usi ng the definition from 40 CFR Part 63 subpart UU.

• The industry representatives also requested that the EPA consider proposing that leaks from a pressure vessel be subject to the same LDAR requirements as other equipment, which provide facilities with an opportunity to re pair detected leaks rather than a leak resulting in an immediate violation of the standards.
6. Vapor BalancingMemorandum, December 9, 2013 Page 4 of 5

• The industry representatives went over issues raised in their petition regarding the omission of vapor balancing from the final rule.
7. Combined Process Vents

• The industry representatives reiterated comments from their June 18, 2012 petition regarding emission limits for combined process ve nts , including applicability of the limits and process vent requirements to other source category processes and the determination of the most stringent s tandard where multiple standards apply to a single emission point.

• The industry representatives presented an approach to “appo rtion” standards for combined process vents.
8. Requirements for Emission Profiles

• The industry representatives reiterated their comments regarding emission profiles from their June 18, 2012 petition for reconsideration. They noted that they agree with the intent of the emission profile requirements as described in the preamble to the final rule, but stated that the rule does not ref lect the discussion of the emission profile provisions in the preamble.

• As stated in their petition, the industry representative s requested that EPA clarify in the proposal the extent of the emission profiles an d at what particular point in the process vent systems they are required. The industr y representatives explained how emission profiles could be skewed or not applicable given the vinyl chloride recovery systems at most manufacturing facilities.
9. Discussion of VI Clarification Letter

• The industry representatives walked through issues raised i n their letter to EPA, dated April 5, 2013 “Re: Clarification on Certain Provisions in the National Emission Standards for Hazardous Air Pollutants for Pol yvinyl Chloride and Copolymers Production (‘PVC MACT’)”.

• The industry representatives stated that stripped resin is stored in feed tanks that are vented to the atmosphere but that these tanks are not considered to be in HAP service.
10. Wastewater Section 114 Survey Request

• The industry representatives indicated they were in the process of reviewing the data submitted to EPA in response to the November 6, 2012 was tewater Section 114 survey request.

• The industry representatives requested another meeting wi th EPA to discuss the results of the testing conducted in response to the Novem ber 6, 2012 Section 114 survey.

• The industry representatives discussed the general vari ability of the measurement data collected, noting that subsets of certain HAP are pr esent for some facilities and not others due to recipe requirements for particular t ypes and grades of resins.Memorandum, December 9, 2013 Page 5 of 5

11. Miscellaneous Topics

• The industry representatives expressed concern with the new source emission limits in the final rule, noting in general that adequate variability may not have been incorporated for the best performers identified by EPA

.

• The industry representatives restated from their petiti on that that they support subcategorization for resin limits, the definition of “ affected source,” the use of the upper prediction limit in MACT floor limit calculati ons, the use of total organic HAP (TOHAP) and not including beyond the floor tec hnology in the final rule provisions.

• The industry representatives noted that an extension of the compliance date may be needed if the EPA changes limits in the standard as par t of reconsideration.Memorandum, December 9, 2013 Attachment A

A-1 

# Attachments

A. Meeting Agenda Submitted by the Vinyl InstitutePage 1 of 2 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271

www.vinylinfo.org www.vinylindesign.com

A-2 May 22, 2013 Sent Electronically Via e-mail

Ms. Andrea Siefers Program Manager U.S. EPA - Office of Air Quality Planning and Stand ards Sector Policies and Program Divisions Refining and Chemicals Group Mail Code: E143-01 Research Triangle Park, NC 27711

RE: Agenda for Vinyl Institute Meeting on May 22, 2 013 (1:00 to 4:00 pm): National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production (PVC MACT) Rule

Dear Ms. Siefers:

The Vinyl Institute PVC MACT Working Group apprecia tes the Agency’s willingness to meet with us to dis cuss our concerns, questions, additional data submission s, and need for clarification of certain provisions of the above-referenced final rule. We have prepared a br ief Agenda for our discussions which should facilit ate the flow of the discussion with some suggested timefram es for the meeting. Should you or your colleagues have any additional items that you wish added for our pr eparation, please feel free to add them to the foll owing topics:

1. Introductions and Opening Remarks (10 min.)

2. Petitions for Reconsideration: EPA Status Update

a. Area Sources (15 min.) b. Limits for Vent Gas Absorbers (20 min.)

c. Bypasses from Closed Vent Systems (10 min.) d. Pressure Relief Device Requirements (20 min.)

e. LDAR for Pressure Vessels (10 min.) f. Vapor Balancing (5 min.)
g. Combined Process Vents (20 min)
i. Status of EDC/VCM rulemaking h. Requirements for Emission Profiles (5 min.)
3. Addressing clarifications (30 min.)
4. S114 Treated Process Wastewater Request (30 min.)
5. Other topics, next steps (5 min.)
6. AdjournmentPage 2 of 2 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271

www.vinylinfo.org www.vinylindesign.com

A-3 At this time, I anticipate the following Working Gr oup members to attend: Mary Bachynsky – Formosa Plastics Barry Christensen – OxyChem John Westendorf – OxyChem David Wise – Shintech Tom Andersen - Shintech Kevin Bloomer – Westlake Allen Bodron – Westlake Otis Sistrunk – PolyOne Ted Nickerson – Axiall Andy Sheppard - URS JC Walker – Keller and Heckman Greg Clark – Keller and Heckman Richard Krock – Vinyl Institute

Tentative attendees include: Laura Whiting - OxyChem

There are a few others that would like to attend bu t their schedules prevent them from doing so. Acco rdingly, I have circulated the coordinates for the teleconfere nce line you set up so they can participate by phon e.
Again, the Working Group appreciates the time and e ffort the Agency has put forth for this rule and yo ur continued willingness to meet with us to ensure the amendments to final rule are fully protective of h uman health and the environment, while allowing the indu stry the flexibility to compete effectively in the global economy. The Working Group looks forward to our di scussions with you on Wednesday, May 22, 2011 at 1: 00 pm. Please do not hesitate to contact me if you ha ve any questions.
Sincerely,

Richard P. Krock Technical Director e-mail: rkrock@vinylinfo.org Phone: 571-970-3392 Cell: 571-216-4474

cc: Penny Lassiter